Item 41 - Amendment Application No. 2022-01 and Appeal Nos. 2022-01 and 2022-02

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City Response to Comment Letter Lozeau Drury, dated October 10, 2022 Response 4: The comment is inaccurate. The GPU EIR analyzed buildout of the GPU, which includes development of the Project site consistent with the designation of FLEX-3 that allows a FAR of 3.0 and building heights up to 10-stories and uses including warehousing, office -industrial flex spaces, small-scale clean manufacturing, research, and development. As detailed on page 2 of the Community Plan Exemption Checklist, the Project would result in a FAR of 0.42, which is substantially less than the analysis of the GPU EIR that evaluated a density of 3.0 FAR on the site. As such, the GPU EIR adequately anticipated and analyzed the impacts of this Project and identified applicable mitigation measures necessary to reduce impacts of the Project. The Project was modeled using CAIEEMod to evaluate both air quality and greenhouse gas emissions, as detailed in the Community Plan Exemption Checklist on pages 34 through 39 and pages 59 and 60, which showed the emissions would not exceed SCAQMD thresholds, and impacts would be less than significant and consistent with the City's Climate Action Plan (page 61). Also, as described on page 36, the GPU EIR determined that the HRA related risk thresholds established by South Coast AQMD would be implemented by Mitigation Measure AQ-3, which details that projects that have the potential to generate 100 or more diesel truck trips per day or have 40 or more trucks with operating diesel- powered transport refrigeration units, and are within 1,000 feet of a sensitive land use (e.g., residential, schools, hospitals, or nursing homes), as measured from the property line of the project to the property line of the nearest sensitive use may result in an impact and would require a health risk assessment (HRA). The proposed Project would only generate 44 non -refrigerated truck trips per day, which is less than the 100 trips that would have the potential to result in an impact. This is consistent with the CARB published document Air Quality Land Use Handbook. A Community Health Perspective' (April 2005) that provides a screening threshold of 100 heavy diesel trucks (one-way) or 200 (two-way) truck trips for potential impacts to occur. Further, the closest residence to the site is approximately 2,200 feet from the Project, which is farther than the 1,000-foot setback recommended by the South Coast AQMD. Thus, the proposed Project was reviewed and determined to not have the potential to result in project -specific significant effects. A screening -level Health Risk Assessment is therefore not necessary for this Project. Comment 5: This comment states that construction of the Project meets the threshold warranting a quantified HRA under Office of Environmental Health Hazard Assessment (OEHHA). The comment also states that the OEHHA document also recommends that if a project is expected to last over 6 months, the exposure should be evaluated throughout the project using a 30-year exposure duration to estimate individual cancer risks, and that it is reasonably assumed that the Project will last at least 30 years, and therefore recommends that health risk impacts from project - generated Diesel Particulate Matter ("DPM") emissions be prepared and that an mitigated negative declaration be prepared to mitigate impacts accordingly. Response 5: The South Coast AQMD does not currently require health risk assessments for short-term emissions from construction equipment. Instead, South Coast AQMD has promulgated a specific methodology for analysis of localized impacts from construction to nearby sensitive receptors as an indicator of potential health risk. The LSTs are the amount of project -related construction emissions at which localized pollutant concentrations would exceed State air quality standards. Additionally, LSTs are designed to protect sensitive receptors most susceptible to https://ww3.arb.ca.gov/ch/handbook.pdf Exhibit 13 Page 2 of 7